Up to now it is not clear how transactions will be executed in the future emissions allowance trading scheme. Although the transfer of emission allowances has been regulated by the emissions trading directive, cash flows have not yet been regulated. "Currently, every market participant has to conclude a bilateral contract with his counterpart, each party's credit standing has to be assessed individually. Due to these market characteristics, many smaller companies don't have the same trading opportunities like big players." describes Markus Hüwener, Managing Director of 3C climate change consulting GmbH in Frankfurt/Germany.

Due to the above mentioned market characteristics 3C calls for a central clearinghouse like it is already in use on the German stock exchange (EUREX) or the European Energy Exchange (EEX). A central clearinghouse of that kind can reduce the counterparty risks as it functions as an intermediary between the market participants.